SECURITIES AND EXCHANGE COMMISSION, Plaintiff,

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NORTH CAROLINA

WESTERN DIVISION

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,

v.

Civil Action File No.

ALTON PERHINS,YILAIME CORPORATION OF NC,YILAIME CORPORATION OF NEVADA, PERKINS HSU EXPORT CORPORATION,AMERICATOWNE HOLDINGS,INC.,and MABIALA PHUATI,

Defendants,

ALTON AND XIANG MEI LIN PERKINS FAMILY TRUST,

Relief Defendant.

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF Plaintiff, Securities and Exchange Commission(the "Commission"),files this Complaint for Injunctive and Other Reliefand alleges as follows:

OVERVIEW 1. This matter involves an offering fraud by Defendant Alton Perkins ("Perkins"), who raised approximately $1.1 million through three unregistered

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private placement offerings oftwo companies controlled by him,Defendant Yilaime Corporation ofNC("Yilaime NC")and Defendant Perkins Hsu Export Corporation("Perkins Hsu")(collectively "Perkins Private Entities")

2. In connection with the fraudulent offer and sale ofthe securities of those companies,Perkins and the Perkins Private Entities made multiple misrepresentations and omissions between approximately January 2014 and April 2015,including the planned use ofthe investment proceeds,the entities' expenses, related party transactions, and Perkins's own compensation. Contrary to those representations,Perkins diverted approximately three-fourths ofthe money raised for various personal expenses,including $580,000 for the purchase ofa home, paying his child's private school tuition, and various living expenses.

3. Perkins also made multiple affirmative representations about his background and qualifications, but failed to disclose his prior criminal and regulatory disciplinary history, including his nolo contendere plea arising from an indictment for fraudulent misappropriation and a desist and refrain order relating to his offer and sale ofsecurities in a prior company.

4. Another Perkins-controlled entity, Yilaime Corporation of Nevada ("Yilaime Nevada")aided and abetted the foregoing fraud by, among other things, acting as the entity through which the investor funds were funneled.

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5. ReliefDefendant Alton and Xiang Mei Lin Perkins Family Trust ("Perkins Family Trust")-- an entity founded and controlled by Perkins and his

wife --was unjustly enriched from the fraud in that it owns the Perkins home purchased with the investors' funds.

6. Along with Perkins and Yilaime NC,Defendant Mabiala Phuati ("Phuati"), who served as Yilaime NC's Vice Chairman and Managing Director, also violated the registration provisions ofthe federal securities laws by,among other things,sending out general solicitation emails seeking investmentsincluding to members ofPhuati's church and the Congolese immigrant communities in North Carolina and Pennsylvania --but failing to ensure that investors were accredited.

7. Finally, between approximately November 2015 and July 2016, Perkins and another Perkins-controlled entity, Defendant AmericaTowne Holdings, Inc.(formerly known as AmericaTowne,Inc.)("AmericaTowne")made false claims in AmericaTowne's public SEC filings, including claiming that the company had two contracts worth nearly $2 million when they knew (or came to know)that the contracts had little, ifany,value.

VIOLATIONS 8. Defendant Perkins has engaged in and, unless restrained and enjoined by this Court, will continue to engage in acts and practices that constitute and will

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constitute violations ofSections 5(a), 5(c)and 17(a)ofthe Securities Act of 1933 ("Securities Act")[15 U.S.C.?? 77e(a),77e(c)and 77q(a)], Section 10(b)ofthe Securities Exchange Act of1934("Exchange Act")[15 U.S.C.? 78j(b)] and Rule

lOb-5 thereunder[17 C.F.R.? 240.1Ob-5],and aided and abetted AmericaTowne's violations ofSection 13(a)ofthe Exchange Act[15 U.S.C.? 78m(a)]and Rules 12b-20, 13a-1, 13a-11, and 13a-13 thereunder. [17 C.F.R.?? 240.12b-20, 240.13a-1, 13a-11, and 13a-13].

9. Defendant Yilaime NC has engaged in and, unless restrained and enjoined by this Court, will continue to engage in acts and practices that constitute and will constitute violations ofSections 5(a), 5(c)and 17(a)ofthe Securities Act [15 U.S.C. ?? 77e(a), 77e(c)and 77q(a)], Section 10(b)ofthe Exchange Act[15 U.S.C. ? 78j(b)] and Rule lOb-5 thereunder[17 C.F.R.? 240.1Ob-5].

10. Defendant Perkins Hsu has engaged in and, unless restrained and enjoined by this Court, will continue to engage in acts and practices that constitute and will constitute violations ofSection 17(a)ofthe Securities Act[15 U.S.C. ? 77q(a)], Section 10(b)ofthe Exchange Act[15 U.S.C. ? 78j(b)] and Rule lOb-5 thereunder[17 C.F.R. ? 240.1Ob-5].

1 1. Defendant Yilaime Nevada has engaged in and, unless restrained and enjoined by this Court, will continue to engage in acts and practices that constitute aiding and abetting Perkins,Yilaime NC,and Perkins Hsu's violations ofSection

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17(a)ofthe Securities Act and Section 10(b)ofthe Exchange Act and Rule lOb-5 thereunder.

12. Defendant Phuati has engaged in and,unless restrained and enjoined by this Court, will continue to engage in acts and practices that constitute violations ofSections 5(a)and 5(c)ofthe Securities Act[15 U.S.C.?? 77e(a), 77e(c)].

13. Defendant AmericaTowne has engaged in and,unless restrained and enjoined by this Court, will continue to engage in acts and practices that constitute and will constitute violations ofSection 13(a)ofthe Exchange Act[15 U.S.C. ? 78m(a)] and Rules 12b-20, 13a-1, 13a-11 and 13a-13 thereunder. [17 C.F.R. ?? 240.12b-20, 240.13a-1, 13a-11, and 13a-13].

DEFENDANTS AND THE RELIEF DEFENDANT

14. Defendant Alton Perkins,68 years old,resides in Wake Forest, North Carolina. Perkins is the Chairman,ChiefExecutive Officer, and majority shareholder ofYilaime NC,Perkins Hsu,AmericaTowne,and Yilaime Nevada.

15. Defendant Yilaime Corporation of NC is a North Carolina corporation formed in May 2013, with its principal place of business in Raleigh, North Carolina. It purports to be in the business ofinternational exports, development, and investments, and is not registered with the Commission in any

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